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Category: Case Summaries

Devalle and the Good Moral Character Requirement for Law Enforcement Officers

Law enforcement officers in North Carolina must have good moral character to be certified, and may lose their certification if they lose their good moral character. The requirement of good moral character is neither unique to North Carolina nor exclusive to law enforcement officers. At the same time, it is a difficult standard to apply, as illustrated by a recent decision issued by the Supreme Court of North Carolina. This post provides context for that decision and explores its reasoning.

Case Summaries: N.C. Supreme Court (August 22, 2025)

This post summarizes the published criminal opinions from the North Carolina Supreme Court released on August 22, 2025. Previously, summaries were added to Smith’s Criminal Case Compendium, but due to personnel changes and resource limitations, that resource is no longer available. We will continue to post and archive new summaries here on the blog.

Case Summaries: N.C. Court of Appeals (Aug. 20, 2025)

This post summarizes the published criminal opinions from the North Carolina Court of Appeals released on August 20, 2025. An indictment for injuring property to obtain non-ferrous metals was sufficient despite the lack of any allegation concerning the value of the property damage. State v. Council, No. COA25-78 (N.C. Ct. App. Aug. 20, 2025) (Hampson). In this Durham County case, the defendant was suspected of stealing a catalytic converter from a truck. He was indicted for, and convicted of, felony larceny and felony injury to property to obtain non-ferrous metals. He appealed, asserting that the indictment for the injury to property charge was defective for failing to specify the value of the property damage.